Even at higher resolutions (16x10, 19x12) and detailed settings his processor would be a bottleneck for a lot of cards.
I'd say any sub-$100 card would work, since the investment isn't too great: HD4670, HD3870, 9600GT, HD4830, 9800GT. With anything faster I doubt you'd pull better framerates than a card like the HD4830. Heck, I'm sure some people here have similar setups.
When I get home I'll run some benchmarks with my HD3850 and different processor speeds and post them for you. If anyone has a high end card, like an HD4870, with an Athlon X2, they can also post some numbers when their processor is underclocked. For reference I'll run benchmarks at 1280x1024 for Team Fortress 2 (custom timedemo), Far Cry 2, 3DMark06, FEAR, HL2: Lost Coast, Company of Heroes Opposing Fronts, and possibly Crysis (I only have the playable demo). I'll run my X2 at 2.0, 2.6, and 3.1 GHz using Vista Ultimate 32-bit and 2xAA across the board, since the jaggies really suck at 1280x1024 and 2x makes a huge difference in IQ. 4xAA also makes a huge difference over 2x, but it really drops my performance in the more demanding games.